FAC Explorer

Finding 616257 (2022-004)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-09-28
Audit: 34720
Organization: Pueblo County Colorado (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: Subrecipients did not receive all required information in their agreements, including critical identifiers like the CFDA number and DUNS number.
  • Impacted Requirements: Compliance with 2 CFR 200.331(a) and 2 CFR 200.303 was lacking, leading to insufficient monitoring and risk evaluation of subrecipients.
  • Recommended Follow-Up: The County should enhance procedures to ensure all necessary information is included in subaward documents and establish effective monitoring practices for subrecipients.

Finding Text

Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient?s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient?s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient?s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County?s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. A subrecipient was provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. Two of the five subrecipients were missing an internal checklist that is signed by the County Manager. One of the five subrecipients was provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: No. Recommendation: We recommend that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 39812 2022-002
    Significant Deficiency
  • 39813 2022-002
    Significant Deficiency
  • 39814 2022-003
    Material Weakness
  • 39815 2022-004
    Material Weakness
  • 39816 2022-005
    Significant Deficiency
  • 39817 2022-003
    Material Weakness
  • 39818 2022-004
    Material Weakness
  • 39819 2022-005
    Significant Deficiency
  • 39820 2022-003
    Material Weakness
  • 39821 2022-004
    Material Weakness
  • 39822 2022-005
    Significant Deficiency
  • 616254 2022-002
    Significant Deficiency
  • 616255 2022-002
    Significant Deficiency
  • 616256 2022-003
    Material Weakness
  • 616258 2022-005
    Significant Deficiency
  • 616259 2022-003
    Material Weakness
  • 616260 2022-004
    Material Weakness
  • 616261 2022-005
    Significant Deficiency
  • 616262 2022-003
    Material Weakness
  • 616263 2022-004
    Material Weakness
  • 616264 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance to Needy Families $9.32M
93.568 Low-Income Home Energy Assistance (dss) $9.08M
97.040 Chemical Stsockpile Emergency Preparedness $4.96M
93.658 Foster Care - Title IV-E $2.91M
93.778 Single Entry Point, Medical Assistance Program $2.75M
93.778 Title Xix, Medicaid Medical Assistance Program $2.55M
93.563 Title IV-D, Child Support Enforcement $2.17M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.92M
93.575 Child Care & Development Block Grant $1.64M
93.659 Adoption Assistance $1.29M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Dvelopment Fund $1.21M
10.569 Emergency Food Assistance Program (food Commodities - Non-Cash) $1.10M
81.042 Weatherization Assistance for Low-Income Persons $692,219
93.044 Title Iii, Part B - Grants for Supportive Services and Senior Centers $650,947
93.568 Low-Income Home Energy Assistance (hhs) $630,567
93.045 Title Iii, Part C - Nutrition Services $630,314
10.565 Commodity Supplemental Food Program (commodities - Non-Cash) $599,637
93.667 Social Services Block Grant - Title Xx $532,596
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $297,702
93.569 Community Services Block Grant $251,674
93.674 Chafee Foster Care Independence Program $201,348
97.067 Homeland Security Grant $171,510
16.922 Federal Forfeiture Funds $157,300
14.231 Emergency Solutions Grant Program $151,129
93.090 Guardianship Assistance $147,049
16.835 Bureau of Justice Body Camera Grant $138,276
16.738 Edward Byrne Memorial Justice Assistance Grant $122,261
10.565 Commodity Supplemental Food Program (admin) $107,660
97.042 Emergency Management Performance Grant $89,784
16.575 Crime Victim Assistance (sheriff) $76,736
93.053 Nutrition Services Incentive Program (usda) $65,836
16.606 State Criminal Alien Assistance Program $57,012
93.645 Child Welfare Services-State Grants Title IV-B $51,258
14.218 Community Development Block Grants/entitlement Grants $35,241
93.634 Applied Research in Child Welfare (arch) $34,794
97.029 Fema - Building Resilient Infrastructure and Communities $33,150
16.575 Crime Victim Assistance (da) $30,348
93.052 Title Iii, Part E - National Family Cargiver Support $26,634
93.041 Title Vii - Chapter 4 - Programs for Prevention of Elder Abuse, Neglect, and Exploitation $25,448
93.747 Covid-19 - Elder Abuse Prevention Interventions Program $12,673
10.569 Emergency Food Assistance Program (admin) $10,000
93.556 Promoting Safe & Stable Families $5,611
93.043 Title III - Part D - Disease Prevention and Health Promotion Services $2,450